Interpretation ID: nht78-1.3

DATE: 12/05/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: U. S. Suzuki Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. F. Michael Petler Assistant Manager Safety & Legislation Department U.S. Suzuki Motor Corporation P.O. Box 2107 Santa Fe Springs, California 90670

Dear Mr. Petler:

This is in response to your letter of August 11, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 127, Speedometers and Odometers.

Standard 127 does not specify that the number "0" appear on the face of the speedometer. It is permissible for you to reletter the "0" mph position to read "5" mph, as the lowest measured speed indicated. This would solve the problem you indicate regarding the relationship of the graduation distance between the 0 and 10 mph to that between 10 and 20, 20 and 30, etc.

The NHTSA has received petitions for reconsideration requesting that the 10 percent deviation requirement be eliminated. A determination will be made at a later date whether to grant the petitions.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

August 11, 1978

Joseph J. Levin, Esquire Chief Counsel National Highway Traffic Safety Administration Room 5219 400 7th Street, S.W. Washington, D.C. 20590

Re: Request for interpretation, FMVSS #127, Speedometers and Odometers

Dear Mr. Levin,

We have been requested by our parent Company, Suzuki Motor Company, Ltd. to request from your agency an interpretation concerning a speedometer faceplate they wish to use. To assist you in understanding our comments we have attached a drawing. I apologize that it is not to the scale of the faceplate. Further, this past July 11, we left a sample faceplate with Mr. Carson of your Crash Avoidance Division, which you might want to examine. Our opinion requests are as follows:

Opinion Request No. 1 --

The area we are concerned with is directed to the speed zone indication area of from 0-10 mph. As you will notice, there are two graduations between 0-20 mph. They represent 10 and 15 mph, no 5 mph graduation is shown. Suzuki has determined that movement of the speedometer indicator needle does not begin to travel from the "0" point until the vehicle has reached approximately "5" mph. As you can see, there is relatively little travel area between the 0-10 mph graduations. We recognize that the graduation distance between 0-10 is not the same as the equal graduations from 10 to 80 mph. We were advised that to relocate the 0 position by removing the needle "0" stop pin could result in possible damage to the unit over an extended period of time, therefore we would pre- fer to be able to retain the faceplate as it is, if it is acceptable to your agency. We believe that the 0-10 mph range is not as critical to the safe operation of the vehicle as those speeds above 10 mph are, and for this reason we request relief in the area of 0-10 mph speed graduation requirements. If, however, this faceplate, in its current form, is unacceptable to your agency, we would then request your opinion on another possible solution that we believe we might be able to utilize.

Opinion Request No. 2

In reviewing Docket No. 76-06, Notice 5 (F.R.Vol.43, N0.145, 7/27/78, page 32422) we noted your agencies comments regarding "Suppressed zero needle". Our question is, since our needle does not move until the vehicle achieves a speed of 5mph, and by applying the suppressed zero needle approach, would Suzuki be permitted to reletter the "0" mph position to "5" mph, as the lowest measured speed indicated on the face of the speedometer. We again feel that the 5 mph starting position would not be critical to the safe operation of the vehicle.

We would appreciate your review of this faceplate design and interpretation as to whether this faceplate would be acceptable in its current state, Opinion Request No. 1 or Opinion Request No. 2, to meet the requirements effective September 1, 1979. If you are in need of any additional information please feel free to contact us.

Thank you for your assistance in this matter.

Sincerely,

F. Michael Petler Assistant Manager Safety & Legislation Deparpment

FMP/ph